Last week, the White House’s Office of Information and Regulatory Affairs (OIRA) approved a survey to be conducted for the Occupational Safety and Health Administration (OSHA) as part of the agency’s efforts to develop an Injury and Illness Prevention Program (I2P2) standard.

Surveys, like this one, have to be approved by OIRA according to the Paperwork Reduction Act, and the lengthy approval may stall development of the I2P2 standard for four or more months for no apparently good reason. OIRA made only minor changes to the draft documents.

The I2P2 standard is OSHA’s signature regulatory initiative, and it comes in the nick of time. With its small and dwindling staff, a result of Congress putting it on a starvation diet of resources, OSHA has found it difficult to update its safety and health standards to protect workers, or to adopt new ones to address hazards that are not yet covered, leaving thousands of workers with inadequate protection.

To fill this gap, Dr. David Michaels, OSHA’s administrator, and a public health expert, has proposed I2P2, a standard that would require employers to establish a management program in which employers and employees work together to identify and address workplace hazards. California already has a version of the standard on the books. The USDA uses a similar system to ensure that meat packers address potential sources of contamination in their plants.